Shortly after Governor Peter Shumlin took office, he said he was very surprised to see that the State Energy Plan included Vermont Yankee operating past March 2012, operating beyond its design date. Now he and his team have put together a proposal for Vermont without Vermont Yankee, the Comprehensive Energy Plan (CEP).

The plan was released by the Department of Public Service (DPS) September 14. The public comment period ends October 10, less than a month later. The CEP covers electricity, heating, transmission, and transportation. It is over 600 pages long, including the appendices. The main volume is 368 pages. Less than a month does not give the public much time to review the documents.

The people of Vermont need more time to study this plan. Even a cursory review shows some serious, basic flaws. The CEP includes ambitious renewable goals, but little actual planning. Among other things, it doesn't address the issue of electricity supply without Vermont Yankee in a straightforward fashion.

For example, in the summary document, the electricity section (pages 7 through 9) includes expansion of the standard offer program for renewable energy, and hiring a new "renewable energy project development director" for DPS. The electricity section does not mention natural gas or acknowledge any gap in the electricity supply.

However, the home and business heating section (pages 10 through 12) does note that there might be an electricity supply gap. On page 11, the heating section encourages the expansion of a gas pipeline into Vermont because "Natural gas can address two key needs: reduce Vermonter's reliance on overseas oil for heating....and help fill a gap in electric supply." (emphasis added).

The CEP contains goals such as 90% of our energy needs by renewable sources by 2050 (page 3 of summary document). There are no numbers or dates for future construction of renewable sources, however. No statements such as "this much wind energy by this date." Yes, the CEP does recapitulate Vermont's historic energy demand and supply sources. But that is not the same as a forward-looking plan.

Vermonters need facts: costs, timelines, sites, hard data about proposed generation and transmission choices. The Institute for Energy and the Environment of Vermont Law School (VLS) recently announced that they had extensive input on the CEP. This is apparent, with many references to "process" and "stake holders" and breathtaking legislative changes. Clearly, Montpelier will be busy. But there is little here that an engineer would call a plan.

Despite its lack of content, the plan has already come under fire from the Vermont Public Interest Research Group (VPIRG ), said Gov. Peter Shumlin’s renewable power goals must be more aggressive. DPS Commissioner Elizabeth Miller reportedly has said she wasn't sure about VPIRG’s numbers. In my opinion, this controversy occurred because the plan has long-term goals and few actual numbers. VPIRG was criticizing numbers that DPS did not explicitly put in the plan.

The plan’s discussion of future greenhouse gas emissions is also problematic. The level of greenhouse gases produced from the electricity sector is shown as rising rapidly after 2012, presumably after Vermont Yankee closes – although this fact is not specified. The chart also shows projections for lowering greenhouse emissions are (at minimum) aggressive, and probably unworkable. It is a chart of goals, not a plan.

But when the State of Vermont states that controlling greenhouse gas emissions is a major energy policy goal, and then all but admits that closing Vermont Yankee will lead to more greenhouse gases, but still maintains that Vermont should close Vermont Yankee anyway – what sense does that make? Why should anyone take this plan’s policy recommendations – ill-defined as they are - seriously?